Federal Trade Commission v. Consumer Defense LLC et al

Filing 305

ORDER Granting 304 Stipulation for Extension of Time re 302 Response (First Request). Signed by Judge James C. Mahan on 10/28/2019. (Copies have been distributed pursuant to the NEF - MR)

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Jonathan Hanley
3241 East Granite Point Circle
Sandy Utah 84092
801-913-5504 |
[e-mail]

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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEVADA

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FEDERAL TRADE COMMISSION,

CASE NO. 2:18-CV-00030-JCM-BNW

Plaintiff,
v.
CONSUMER DEFENSE, LLC, et. al.,

STIPULATION TO EXTEND
DEFENDANTS REPLY DEADLINE TO
PLAINTIFFS RESPONSE (ECF NO. 302)

Defendants.

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STIPULATION

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COME NOW, Jonathan Hanley in his capacity as Defendant pro se and Defendants,
CONSUMER DEFENSE, LLC; CONSUMER LINK, INC. AMERICAN HOME LOAN
COUNSELORS; AMERICAN HOME LOANS, LLC; CONSUMER DEFENSE GROUP, LLC
F/K/A MODIFICATION REVIEW BOARD, LLC; BROWN LEGAL, INC.; FMG PARTNERS,

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LLC; ZINLY, LLC; SANDRA X. HANLEY, by and through their attorney of record, and the

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Plaintiff, FEDERAL TRADE COMMISSION, by and through its attorneys of record, and hereby

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stipulate, agree and seek this Court’s Order as follows:

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STIPULATION TO EXTEND DEFENDANTS REPLY DEADLINE TO PLAINTIFFS RESPONSE (ECF NO.
302) - 1

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along with an accompanying response on October 4th 2019 (ECF No. 295) in response to

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Defendant Jonathan Hanley filed a Request for Relief pursuant to Fed. R. Civ. P. 56(d)

Plaintiff FTC’s Motion for Summary Judgment filed on July 16th 2019. (ECF No. 255)
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Plaintiff FTC filed a response to Hanley’s Request for 56(d) Relief on October 18th 2019.

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3.

Hanley has asked Plaintiff FTC if they are amenable to agreeing to an October 28th reply

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deadline with respect to Plaintiff’s response concerning Hanley’s Fed. R. Civ. P. 56(d) request.

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4.

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The juncture that this litigation is at is extraordinarily time consuming for a pro se

defendant who also must also manage attempting to support a family. Hanley has represented
to Plaintiff FTC that he has been diligently working on matters concerning this litigation and

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does not request this extension for any purposes of delay.

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5.

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302) on Monday October 28th 2019.

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6.

The parties agree that Hanley may file his reply to Plaintiff FTC’s response (ECF No.

This stipulation is made in good faith among and at the request of the parties, and not for

purposes of delay.

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BOGGESS LAW GROUP

ALDEN F. ABBOTT
General Counsel

/s/D. Brian Boggess (with permission)
D Brian Boggess
Nevada Bar No. 4537
7495 West Azure Drive, Suite 211
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Defendants

/s/Gregory A. Ashe (with permission)
GREGORY A. ASHE
JASON SCHALL
Federal Trade Commission
600 Pennsylvania Avenue NW
Washington, DC 20580
Telephone: [phone] (Ashe)
Telephone: [phone] (Schall)
Facsimile: 202-326-3768
Email: [e-mail], [e-mail]

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STIPULATION TO EXTEND DEFENDANTS REPLY DEADLINE TO PLAINTIFFS RESPONSE (ECF NO.
302) - 2

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Dated: October 25th 2019

Respectfully Submitted,

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/s/ Jonathan Hanley
Jonathan P. Hanley

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IT IS SO ORDERED:

______________________________
Honorable James C. Mahan
United States District Judge

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October 28, 2019
DATED:_______________________

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STIPULATION TO EXTEND DEFENDANTS REPLY DEADLINE TO PLAINTIFFS RESPONSE (ECF NO.
302) - 3